EU VAT Refund Deadline: Are You Leaving Money on the Table?

Many Spanish businesses incur VAT in other EU Member States and simply treat it as a cost. As a result, valuable VAT refunds often go unclaimed.

If your business incurred VAT elsewhere in the EU during 2025, you may still be able to recover that VAT. However, claims must be submitted by 30 September 2026.

Miss the deadline and the opportunity to recover that VAT may be lost.

Why might your business be due a refund?

Foreign VAT may be recoverable on costs including:

• Trade fairs, exhibitions and industry conferences.
• Hotel and accommodation costs.
• Business travel expenses.
• Vehicle hire and fuel.
• Overseas training and seminars.
• Professional services received abroad.
• Local purchases and project costs incurred in other EU Member States.

While individual amounts may appear relatively small, they can add up significantly over a year, particularly for businesses with international customers, overseas suppliers or employees who travel regularly.

What is the procedure for applying for a refund?

To reclaim VAT paid in another EU country, we must submit the relevant application using Form 360, which must be submitted electronically through the Spanish Tax Agency’s online portal. The Spanish Tax Authorities then forwards the claim to the relevant Member State for review and processing. Supporting invoices and documentation may be required as part of the claim.

Importantly, VAT recovery rules vary between Member States. Each country may apply different rules around eligible costs, documentation, deduction restrictions and exclusions. Reviewing the VAT incurred before submitting a claim can therefore help identify what is potentially recoverable and reduce the risk of delays or rejected claims.

What are the requirements for obtaining the refund?

•  To be a business or professional and to be acting as such.
• Not to carry out exclusively transactions that do not give rise to the right to a full tax deduction.
• Not carry out exclusively activities taxed under the special schemes for agriculture, livestock farming and fishing or under the equivalence surcharge.
• The total amount included in an application for an annual refund must not be less than 50 euros.
• Have a digital signature and be registered for the electronic notification service. However, if the applicant acts through a third party (representative), they are not required to be subscribed to the electronic notification service, nor do they need to hold their own electronic certificate (the representative must, however, hold one).

Why act now?

Businesses can miss valuable VAT refund opportunities for relatively simple reasons:

• Foreign VAT has been posted to expense accounts rather than identified separately.
• Supporting documentation has not been gathered.
• Overseas VAT has accumulated across multiple countries and business units.
• The review is left until the weeks before the deadline.

A simple review of foreign VAT incurred during 2025 can often uncover refund opportunities that improve cash flow with no impact on day-to-day operations.

How Forvis Mazars can help

Our Indirect Tax team can assist with:

• Identifying potentially recoverable foreign VAT.
• Assessing country-specific recovery restrictions.
• Preparing and submitting EVR claims.
• Managing queries raised by foreign tax authorities.
• Maximising VAT recovery while ensuring compliance.

Whether your business has incurred foreign VAT on travel, exhibitions, professional services or local operating costs, we can help determine whether a refund opportunity exists.

With the 30 September 2026 deadline approaching, contact our Indirect Tax team to discuss your 2025 EU VAT costs and potential refund opportunities.